Preview
BUR-L-000190-16 10/16/2023 Pg 1 of 5 Trans ID: LCV20233134868
Filed with the Court
ocT 16 2023
Eric G. Fikry, J.S.C.
EDITED I}Y THE COTIRT:
SUPERIOR COURT OF NEW JERSEY
JAMIE VALENTINE. ADMINISTRATOR LAW DIVISION - CIVIL PART
AND ADMINISTRATOR AD BURLINGTON COL,]NTY
PROSEQUENDUM OF THE ESTATE OF DOCKETNO. L-I90-I6
JAMES PATTERSON, DECEASED,
CIVIL ACTION
Plaintifl
ORDER
(POLICY STATEMENTS)
CARE ONE AT MOORESTOWN, LLC d/b/A
CARE ONE AT MOORESTOWN, CARE
ONE MANAGEMENT, LLC,
HEALTHBRIDCE MANAGEMENT, LLC,
VIRTUA MEMORIAL HOSPITAL,
VIRTUA MARLTON HOSPITAL, and
VIRTUA HEALTH. INC.
Defendants.
THIS MATTER having been brought before the Court on a Motion in limine by
Defendants, Care One at Moorestown, LLC d/b/a Care One at Moorestown ("Care One"),
represented by Anthony Cocca, Esq. and Katelyn E. Cutinello, Esq. of Cocca & Cutinello, LLP
for an Order barring Plaintifffrom asking questions relating to deviations from Care One's policy
statements, and seeking to exclude Care One's policy statements from evidence; and with
Opposition to the motion by Plaintiff, Jamie Valentine, Administrator and Administrator ad
Prosequendum ofthe Estate ofJames Patterson, Deceased, represented by Matthew E. Gallagher,
Esq. of Swartz Culleton PC; and the Court having considered the submissions of the parties, the
oral arguments ofcounsel, ifany, and for good cause shown:
IT IS on this l6th day of October,2023 ORDERED:
BUR-L-000190-16 10/16/2023 Pg 2 of 5 Trans ID: LCV20233134868
Defendants' Motion ilr limine for an Order barring Plaintiff from
asking questions relating to deviations from Care One's policy
statements, and seeking to exclude Care One's policy statements
from evidence is GRANTED IN PART AND DENIED IN PART.
for the reasons set forth on the record.
IT IS FURTHER ORDERED that inquiry may be conducted into
the Care One Policy Statement captioned, "Repositioning" (Bates
Nos. 1655-1657), so long as no reference is made to the portions of
that policy which have been stricken in the attached modified copy
ofthe Policy Statement. In addition, a redacted version ofthe Care
One Policy Statement captioned, "Repositioning" may be offered
into evidence if plaintiff seeks to do so.
IT IS FURTHER ORDERED that the Care One Policy Statement
captioned "Charting and Documentation" (Bates No. 1652) shall be
EXCLUDED from evidence, and no party may inquire as to same,
for the reasons set forth on the record.
Plaintiff has WITHDRAWN its request to rnake inquiry into the
Care One Policy Statement captioned "Charting Errors and/or
Omissions" (Bates No. 1653).
2. Provisions in Prior Orders Not Modified Herein Remain in
Effect. Any provision(s) in prior Orders ofthe Court not modified
herein remain in full force and effect.
3 IT IS FURTHER ORDERED thar a copy of this order shall be
deemed served upon all counsel and parties of record upon its being
posted to eCourts.
s/ Eric G. Fikry. J.S.C
HON. ERIC G. FIKRY, J.S.C.
x Opposed
tr Unopposed
BUR-L-000190-16 10/16/2023 Pg 3 of 5 Trans ID: LCV20233134868
BUR-L-000190-16 1011312023 3:53:57 PM Pg4 ol 12 Trans lD: LCV20233116228
PositioninE onll Moting
Repositioning Level II
Purpose The purpose of this procedure is to provide guidclines for the evaluation of resident
repositioning needs, to aid in the development of an individualized carc plan for
repositioning, to promote comfort for all bed- orohoi+$ound residcnts and to prevent skin
breakdown, promote circulation and provide pressure relief for residents.
Preparation l. Review the resident's care plan to evaluale for any special needs ofthe resident
2. Assemble the equipment and supplies as needed.
General Guidelines l. Repositioning is a common, effective intervention for preventing skin breakdown,
promoting circulation, and providing pressure rclief.
2. Evaluation of a resident's skin integrity afier pressure has been reduced or
redistributed should guide the development and implementation of repositioning
plans. Such plans should be addressed in the comprehensive plan of care consistent
with the resident's needs and goals.
3. Repositioning is critical for a resident who is immobile or dependent upon staff for
repositioning.
4. The care plan for a resident at risk of friction or shearing during repositioning may
require the use oflifting devices for reposilioning.
5. Positioning the resident on an existing pressurc ulcer should be avoided since it puts
additional pressure on tissue that is already contpromised and may impede healing.
Evaluation Evaluation for Approprirte Repositioning
l. Evaluate residents who can reposition independently to determine the follo\a'ing:
a. Is a positioning device needed to maintain independent positioning?
b. Does lhe resident need instruction about why turning is important?
c. Does lhe resident need encouragement to rePosition?
d. Does the resident require monitoring to assure that tuming occuls?
2. Evaluate the rcsident for an existing pressure ulcer. If present, positioning the
resident on the existing ulcer should be avoided.
+:---B.akatcftsidc tsryho-sit-onccHtrsin.achairryidt{he-bac+{'flhslhr(rt'thc&eF-
ctrhobedlelevere4tecrebevea30degree.$gle;-
-a,--Deoethc+rxiilsnt€ood€Gh€d,t l€+po{ti{iea-thenges?--
-b.--Dee+the*txialen+noodpesitierro*rer+ges-more*eqt€6{lr{&a++our+y?-
.4:----€=nrponentsto.erchrate wh€n-a-t6idenf isi+aekirr-
-lL--Doe$,lh€-r€sidect{Eedjnt€p€nlio$.1&mainteio+est$.Lrl[nnent9--
-b--Js-the+€6id6nl'.e.$,eigh{di€tributix+v€.+-
-€,--Doos{h&r3rident{r.&orriooste{lei ein-riuieg-bahne+}-
-d--J€-thc-+oeidqrtoSbr*h*m?-l€sq+oaeh+osidon+te+&i.ff-hieArcrrroigt*-evoryl-l--
-sringtoeerhilei+thc-ehir--
5. Does the resident have a Stage I prcssure ulcer?
6. What is the support surface in use?
conrinu?s on ,rext page
Nuiring Scrvices Policy and Procedurc Manual
l6
O 2001 MED-PASS, Inc. (Revised April20l3)
Pattsrson v. Care Ons at Moorestorvn, Et al; Docket No. BUR-L-19G16 - CONFIDENTIAL - Care On€ 1655
BUR-L-000190-16 10/16/2023 Pg 4 of 5 Trans ID: LCV20233134868
BUR-L-000190-16 10113120233:53:57 PM Pg 5 ot 12 Trans lD: LCV20233116228
Posilioningand Moring
Interventions/ A tuming/rcpositioning program includcs a continuous consistcnt program for changing thc
resident's position and realigning the body. A program is defined as a specific approach that
Care Stratcgies
is organized, planned, documented, monitored and evaluated.
L Frequency ofrepositioning a bed-oroheir-bounC resident should be determined by:
a- The type ofsuppon surface used;
b. The condition ofthe skin;
c. The overall condition ofthc resident;
d. The rcsponse to the current repositioning schedule; and
e. Overall treatment objectives.
2. Residents who are in bed should be on at least an every two hour (q2 hour)
rcpositiorting schedule.
-3.---Se:-rr$kl€nle-u.ith-a-Srage*or<$er.e?+oesure+rlcer,-en+r.ery-t'.vo$eur-(qlJteur)-
-repostioning-s€he&!e.isimdequare.-
--+----Residcnts.#hoanqitrr-chat*Mtbe-ortrtt rct onchot r'G++Elriac!6sitionittg-
-s€Mtrls.
5. Ifineffective, the tuming and repositioning frequency will be increased.
6. Avoid placing resident on the greater trochanter tbr more than momenlary
placement.
Preparation l. Rcview the resident's carc plan to evaluatc for any spccial needs ofthc resident.
2. Assemble the equipment and supplies as needed.
Equipment and The following equipment and supplies will be necessary when repositioning.
Supplies
L Personal protective equipment (e.9., gowns, gloves, mask, etc., as needed).
Steps in the Repositioning the Resident in Bed
Procedure
Check the care plan, assignment sheet or the communication system to determine
resident's specific positioning needs including special equipment, resident level of
participation and the number of staffrequired to complete the procedure.
2 Wash and dry hands thoroughly.
3 Apply gloves.
4 Raise the bed to waist level.
5 Lower the side rail, ifapplicable, on the side where you are standing.
6 Encoumge the resident to participate ifable.
'7
Lower the sheets.
8 Check for incontinence. Follow steps to care for the incontinent resident, if
neccssary.
9 Use two people and a draw sheet to avoid shearing while tuming or moving the
resident up in bed. Encourage resident to place feet flat on bed and assist with
pushing up. Encourage the use ofan overhead trapeze ifresident is able to use one.
IO Raise the head of the bed as linle and for as shon of a lime as possible, and only as
necessary for meals, treatments arld as medically necessary.
ll Move the resident to his or her back.
t2 Move the residcnt's top lcg and shoulder in thc direction ofthe tum.
l3 Encouage resident to hold the side rail with the top alm in the direction of the turn,
ifpossible.
14. Place the resident in a comfortable position in accordance with the resident's
individualized care plan.
15. Prevent skin-to-skin contact with use ofsheets, pillows or positioning dcvices.
continues on next page
Nursing Serviccs Policyand Procedure Manual
l'l
O 2001 MED-PASS, Inc. (Revised April 20ll)
Patlerson v. Care Ono at Moorestown, et al; Dockst No. BUR-L-I9G16 - CONFIDENTIAL . Care One 1656
BUR-L-000190-16 10/16/2023 Pg 5 of 5 Trans ID: LCV20233134868
BUR-L-000190-16 10113120233:53:57 PM Pg 6of 12 Trans lD: LCV20233116228
Positioninqa l Motinx
Steps in the 16. Lowcr the bcd into lowcst position and placc thc sidc rails in the appropriatc position
as indicated in the resident's plan ofcare.
Proccdure
(continued)
l'7, Reposition the bed covers. Make the residenl cornfodable.
18. Place the call light within easy reach ofthe resident.
19. Wash and dry hands thoroughly.
20. Ifthe resident desires, retum the door and cunains to the open position and ifvisitors
are \r'aiting, tell them that they may now enter the room.
-Rcpositio rg:theResidentint{rc€h*r ( E NTI R E S ECTI ON TO B E RE DACTE D)
l. Encourage the chair-bound resident, who is able to move, to change positions or shift
weight at least every fifteen (15) minutes, or as often as possible.
2. Check the care plan, assignment sheet or the communication system to detemine
residenGspecific positioning needs including special equipment; resident level of
panicipation and the number ofstaffrequircd to complete the procedure.
3. Ask the resident's permission to reposition or assist in repositioning. Take the
resident to a private location, if inrlicated.
4. Assist the resident to change his or her posiiion in the chair. Monitor the need for
toileting or incontinence care when changing position.
5. Place resident in a comfortable position in accordance with the resident's
individualized care plan.
6. Prcvent skin to skin contact with use of sheets, pillo$s or positioning devices
7. Wash and dry your hands thoroughly.
(ENTIRE SECTION O BE REDACTED)
l. The position in which the resident was placed. This may be on a flow sheet.
2. Thc namc and title ofthc individual who gavc the carc.
3. Any change in the resident's condition.
4. Any problems or complaints made by the residcnt related to the procedue.
5. Ifthe resident refused the care and the reason(s) why.
6. Observations ofanything unusual exhibited by the resident.
7. The signature and titlc ofthe person recording the data.
Reporting l. Notiry the supervisor ifthe residenl refuses the procedure.
2. If the resident refuses care, an evaluation of the basis for refusal, and the
identification and evaluation ofpotential altematives is indicated.
3. Report other information in accordance wrth facility policy and professional
standards of practice.
References
MDs (CAAS) Section M; (CAA l6)
Survey Tag Numbers F309; F314
Related Documeots Tum./Reposition Record (MP 5477) (See C D- RO !4)
Risk of Exposure Blood-Body Fluids-Infectious Diseases-Air Contaminants-Hazardous Chemicals
Date; By
Procedure Date: By
Revised Date: By
Date: By
Nursing Scrvices Policy and Proccdurc Manual
l8
O 2001 MED-PASS, Inc. (Revised April 2013)
Pattorson v. Care On6 al Moorestown, ot al; Docket No. BUR-L-190-16 - CONFIDENTIAL - Caro Ono '1657
Preview
BUR-L-000190-16 10/16/2023 Pg 1 of 5 Trans ID: LCV20233134868 Filed with the Court ocT 16 2023 Eric G. Fikry, J.S.C. EDITED I}Y THE COTIRT: SUPERIOR COURT OF NEW JERSEY JAMIE VALENTINE. ADMINISTRATOR LAW DIVISION - CIVIL PART AND ADMINISTRATOR AD BURLINGTON COL,]NTY PROSEQUENDUM OF THE ESTATE OF DOCKETNO. L-I90-I6 JAMES PATTERSON, DECEASED, CIVIL ACTION Plaintifl ORDER (POLICY STATEMENTS) CARE ONE AT MOORESTOWN, LLC d/b/A CARE ONE AT MOORESTOWN, CARE ONE MANAGEMENT, LLC, HEALTHBRIDCE MANAGEMENT, LLC, VIRTUA MEMORIAL HOSPITAL, VIRTUA MARLTON HOSPITAL, and VIRTUA HEALTH. INC. Defendants. THIS MATTER having been brought before the Court on a Motion in limine by Defendants, Care One at Moorestown, LLC d/b/a Care One at Moorestown ("Care One"), represented by Anthony Cocca, Esq. and Katelyn E. Cutinello, Esq. of Cocca & Cutinello, LLP for an Order barring Plaintifffrom asking questions relating to deviations from Care One's policy statements, and seeking to exclude Care One's policy statements from evidence; and with Opposition to the motion by Plaintiff, Jamie Valentine, Administrator and Administrator ad Prosequendum ofthe Estate ofJames Patterson, Deceased, represented by Matthew E. Gallagher, Esq. of Swartz Culleton PC; and the Court having considered the submissions of the parties, the oral arguments ofcounsel, ifany, and for good cause shown: IT IS on this l6th day of October,2023 ORDERED: BUR-L-000190-16 10/16/2023 Pg 2 of 5 Trans ID: LCV20233134868 Defendants' Motion ilr limine for an Order barring Plaintiff from asking questions relating to deviations from Care One's policy statements, and seeking to exclude Care One's policy statements from evidence is GRANTED IN PART AND DENIED IN PART. for the reasons set forth on the record. IT IS FURTHER ORDERED that inquiry may be conducted into the Care One Policy Statement captioned, "Repositioning" (Bates Nos. 1655-1657), so long as no reference is made to the portions of that policy which have been stricken in the attached modified copy ofthe Policy Statement. In addition, a redacted version ofthe Care One Policy Statement captioned, "Repositioning" may be offered into evidence if plaintiff seeks to do so. IT IS FURTHER ORDERED that the Care One Policy Statement captioned "Charting and Documentation" (Bates No. 1652) shall be EXCLUDED from evidence, and no party may inquire as to same, for the reasons set forth on the record. Plaintiff has WITHDRAWN its request to rnake inquiry into the Care One Policy Statement captioned "Charting Errors and/or Omissions" (Bates No. 1653). 2. Provisions in Prior Orders Not Modified Herein Remain in Effect. Any provision(s) in prior Orders ofthe Court not modified herein remain in full force and effect. 3 IT IS FURTHER ORDERED thar a copy of this order shall be deemed served upon all counsel and parties of record upon its being posted to eCourts. s/ Eric G. Fikry. J.S.C HON. ERIC G. FIKRY, J.S.C. x Opposed tr Unopposed BUR-L-000190-16 10/16/2023 Pg 3 of 5 Trans ID: LCV20233134868 BUR-L-000190-16 1011312023 3:53:57 PM Pg4 ol 12 Trans lD: LCV20233116228 PositioninE onll Moting Repositioning Level II Purpose The purpose of this procedure is to provide guidclines for the evaluation of resident repositioning needs, to aid in the development of an individualized carc plan for repositioning, to promote comfort for all bed- orohoi+$ound residcnts and to prevent skin breakdown, promote circulation and provide pressure relief for residents. Preparation l. Review the resident's care plan to evaluale for any special needs ofthe resident 2. Assemble the equipment and supplies as needed. General Guidelines l. Repositioning is a common, effective intervention for preventing skin breakdown, promoting circulation, and providing pressure rclief. 2. Evaluation of a resident's skin integrity afier pressure has been reduced or redistributed should guide the development and implementation of repositioning plans. Such plans should be addressed in the comprehensive plan of care consistent with the resident's needs and goals. 3. Repositioning is critical for a resident who is immobile or dependent upon staff for repositioning. 4. The care plan for a resident at risk of friction or shearing during repositioning may require the use oflifting devices for reposilioning. 5. Positioning the resident on an existing pressurc ulcer should be avoided since it puts additional pressure on tissue that is already contpromised and may impede healing. Evaluation Evaluation for Approprirte Repositioning l. Evaluate residents who can reposition independently to determine the follo\a'ing: a. Is a positioning device needed to maintain independent positioning? b. Does lhe resident need instruction about why turning is important? c. Does lhe resident need encouragement to rePosition? d. Does the resident require monitoring to assure that tuming occuls? 2. Evaluate the rcsident for an existing pressure ulcer. If present, positioning the resident on the existing ulcer should be avoided. +:---B.akatcftsidc tsryho-sit-onccHtrsin.achairryidt{he-bac+{'flhslhr(rt'thc&eF- ctrhobedlelevere4tecrebevea30degree.$gle;- -a,--Deoethc+rxiilsnt€ood€Gh€d,t l€+po{ti{iea-thenges?-- -b.--Dee+the*txialen+noodpesitierro*rer+ges-more*eqt€6{lr{&a++our+y?- .4:----€=nrponentsto.erchrate wh€n-a-t6idenf isi+aekirr- -lL--Doe$,lh€-r€sidect{Eedjnt€p€nlio$.1&mainteio+est$.Lrl[nnent9-- -b--Js-the+€6id6nl'.e.$,eigh{di€tributix+v€.+- -€,--Doos{h&r3rident{r.&orriooste{lei ein-riuieg-bahne+}- -d--J€-thc-+oeidqrtoSbr*h*m?-l€sq+oaeh+osidon+te+&i.ff-hieArcrrroigt*-evoryl-l-- -sringtoeerhilei+thc-ehir-- 5. Does the resident have a Stage I prcssure ulcer? 6. What is the support surface in use? conrinu?s on ,rext page Nuiring Scrvices Policy and Procedurc Manual l6 O 2001 MED-PASS, Inc. (Revised April20l3) Pattsrson v. Care Ons at Moorestorvn, Et al; Docket No. BUR-L-19G16 - CONFIDENTIAL - Care On€ 1655 BUR-L-000190-16 10/16/2023 Pg 4 of 5 Trans ID: LCV20233134868 BUR-L-000190-16 10113120233:53:57 PM Pg 5 ot 12 Trans lD: LCV20233116228 Posilioningand Moring Interventions/ A tuming/rcpositioning program includcs a continuous consistcnt program for changing thc resident's position and realigning the body. A program is defined as a specific approach that Care Stratcgies is organized, planned, documented, monitored and evaluated. L Frequency ofrepositioning a bed-oroheir-bounC resident should be determined by: a- The type ofsuppon surface used; b. The condition ofthe skin; c. The overall condition ofthc resident; d. The rcsponse to the current repositioning schedule; and e. Overall treatment objectives. 2. Residents who are in bed should be on at least an every two hour (q2 hour) rcpositiorting schedule. -3.---Se:-rr$kl€nle-u.ith-a-Srage*or<$er.e?+oesure+rlcer,-en+r.ery-t'.vo$eur-(qlJteur)- -repostioning-s€he&!e.isimdequare.- --+----Residcnts.#hoanqitrr-chat*Mtbe-ortrtt rct onchot r'G++Elriac!6sitionittg- -s€Mtrls. 5. Ifineffective, the tuming and repositioning frequency will be increased. 6. Avoid placing resident on the greater trochanter tbr more than momenlary placement. Preparation l. Rcview the resident's carc plan to evaluatc for any spccial needs ofthc resident. 2. Assemble the equipment and supplies as needed. Equipment and The following equipment and supplies will be necessary when repositioning. Supplies L Personal protective equipment (e.9., gowns, gloves, mask, etc., as needed). Steps in the Repositioning the Resident in Bed Procedure Check the care plan, assignment sheet or the communication system to determine resident's specific positioning needs including special equipment, resident level of participation and the number of staffrequired to complete the procedure. 2 Wash and dry hands thoroughly. 3 Apply gloves. 4 Raise the bed to waist level. 5 Lower the side rail, ifapplicable, on the side where you are standing. 6 Encoumge the resident to participate ifable. '7 Lower the sheets. 8 Check for incontinence. Follow steps to care for the incontinent resident, if neccssary. 9 Use two people and a draw sheet to avoid shearing while tuming or moving the resident up in bed. Encourage resident to place feet flat on bed and assist with pushing up. Encourage the use ofan overhead trapeze ifresident is able to use one. IO Raise the head of the bed as linle and for as shon of a lime as possible, and only as necessary for meals, treatments arld as medically necessary. ll Move the resident to his or her back. t2 Move the residcnt's top lcg and shoulder in thc direction ofthe tum. l3 Encouage resident to hold the side rail with the top alm in the direction of the turn, ifpossible. 14. Place the resident in a comfortable position in accordance with the resident's individualized care plan. 15. Prevent skin-to-skin contact with use ofsheets, pillows or positioning dcvices. continues on next page Nursing Serviccs Policyand Procedure Manual l'l O 2001 MED-PASS, Inc. (Revised April 20ll) Patlerson v. Care Ono at Moorestown, et al; Dockst No. BUR-L-I9G16 - CONFIDENTIAL . Care One 1656 BUR-L-000190-16 10/16/2023 Pg 5 of 5 Trans ID: LCV20233134868 BUR-L-000190-16 10113120233:53:57 PM Pg 6of 12 Trans lD: LCV20233116228 Positioninqa l Motinx Steps in the 16. Lowcr the bcd into lowcst position and placc thc sidc rails in the appropriatc position as indicated in the resident's plan ofcare. Proccdure (continued) l'7, Reposition the bed covers. Make the residenl cornfodable. 18. Place the call light within easy reach ofthe resident. 19. Wash and dry hands thoroughly. 20. Ifthe resident desires, retum the door and cunains to the open position and ifvisitors are \r'aiting, tell them that they may now enter the room. -Rcpositio rg:theResidentint{rc€h*r ( E NTI R E S ECTI ON TO B E RE DACTE D) l. Encourage the chair-bound resident, who is able to move, to change positions or shift weight at least every fifteen (15) minutes, or as often as possible. 2. Check the care plan, assignment sheet or the communication system to detemine residenGspecific positioning needs including special equipment; resident level of panicipation and the number ofstaffrequircd to complete the procedure. 3. Ask the resident's permission to reposition or assist in repositioning. Take the resident to a private location, if inrlicated. 4. Assist the resident to change his or her posiiion in the chair. Monitor the need for toileting or incontinence care when changing position. 5. Place resident in a comfortable position in accordance with the resident's individualized care plan. 6. Prcvent skin to skin contact with use of sheets, pillo$s or positioning devices 7. Wash and dry your hands thoroughly. (ENTIRE SECTION O BE REDACTED) l. The position in which the resident was placed. This may be on a flow sheet. 2. Thc namc and title ofthc individual who gavc the carc. 3. Any change in the resident's condition. 4. Any problems or complaints made by the residcnt related to the procedue. 5. Ifthe resident refused the care and the reason(s) why. 6. Observations ofanything unusual exhibited by the resident. 7. The signature and titlc ofthe person recording the data. Reporting l. Notiry the supervisor ifthe residenl refuses the procedure. 2. If the resident refuses care, an evaluation of the basis for refusal, and the identification and evaluation ofpotential altematives is indicated. 3. Report other information in accordance wrth facility policy and professional standards of practice. References MDs (CAAS) Section M; (CAA l6) Survey Tag Numbers F309; F314 Related Documeots Tum./Reposition Record (MP 5477) (See C D- RO !4) Risk of Exposure Blood-Body Fluids-Infectious Diseases-Air Contaminants-Hazardous Chemicals Date; By Procedure Date: By Revised Date: By Date: By Nursing Scrvices Policy and Proccdurc Manual l8 O 2001 MED-PASS, Inc. (Revised April 2013) Pattorson v. Care On6 al Moorestown, ot al; Docket No. BUR-L-190-16 - CONFIDENTIAL - Caro Ono '1657